1994-03-23_HYDROLOGY - M1977378 (2)

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Sunny" Gold Corporation Much 23, IOU page 2 The water Quality Control Division does not agree with this position, No has serious concerns about the monitodng program that has ban Wopoeed. Tbese concwo are outlined below. 1) There is no doamented plan for how the data will be analysed, either during or after its collection. Wkkmt using Stallstical methods to analyse the dabs at the completion of the proposed five year sampling period, it is likely that a simple comparison of pre-pluming against post•pluggi"data at each individual sampling site will pwdstce widely varying moults that win be more ngeWvs of siporsdic random variations in loading than rspreseopttive of overall treads. It is also unclear bow the Corporation lntw& to discriminate between those variations in loading that :sight be due b seasonal or year-to-year hydrologic conditions and those variations that are satnally caused by the P"99 g project• 2) Without]mowing how the data will be analysed, it is not clew whether or not as adequate bseelinrs datseet has been sommulmod. While soma additional besdine data may be awil *efts:the tunnels am plugged, due to the fact that it will take some time far the thine pool to reach its ultimate equilibrium elevation, only 2o% of the originally identltfed sample sit" will be monitored fot metals is any given year. Also, the location of sites in relation to the pool elevation will not be a (lector considered in the selection of situ to be sampled. Therefore, it Is UWy that some seeps would only be sampled once beibre the pool elevation rim above the seep elevation,pmvcling a single data point fbr oomparfson purposes. If the pool elevation rim Eater theses predicted, which has be= observed - ia other plugging operations, the number of sits with multiple, baseline obeervadons will be very lfmhW. 3) Again, without knowing bow the data will be analyzed, it is cot possible to judge whether or not the proposed sampling h queacy is adequate. If pm and post-plugging data L to be comparw an a XIWby-site basis, the proposed frequency of once in live years would probably be inadequate. In order to address these wnoerm,the Corporation and our Division must come to an agreement upon some basic priacipka misted to the goals of the monitoring program, as Well as agroon"tt upon the methods and decision crlm& that will allow those goals to be aehleved. As an initial effort to ldendiy site central faun that must be resolved, Wire propose the lbllowing goats and supportleS objectives be used ce e basis for tbsthes discussion. A) The overall god of the monitoring program should be to detect long-term trends in the ioadfng of pollutants to receiving watt n, and if required to protect certain 1>sdividual stream segments, to idatity the apech4k sources of such loading. 11) no general approach taken to compare pre used post-plugging loadings must be defltted. The sites whom losdltip will bs compared must be determined, as well as the type of statistical analyses that will be used to perform the comparisons. C) The boodlue loasffitg Condition must be ideWfled. It may be necessary to delay the pluWag of the ft els usstll enough data has been collected to statistically chacaete:in existing loadings with confldeace. The time PdW br delay Is directly related to the sutistical analysis, sad the Division does not have etaottgh inbratadon to propose a sped&time!came. The required sampling lroqusecy should be teased upon the overall method of analysis that will be used. It will probably be necessary to perform at least monthly analyses to account for seasonal variations. As data is collected, anslyou could be performed to Identify when an adequate number of sampler has been collected.